Chapter 2. Alternatives

Environmental Assessment Continental Divide National Scenic Trail Relocation

CHAPTER 2. ALTERNATIVES

A. Introduction

An Interdisciplinary Team (IDT), representing various resources and uses of the Forests, developed a range of reasonable alternatives to the Proposed Action. The IDT identified relevant issues that were presented during public scoping meetings and formulated alternatives to the Proposed Action in response to these issues. This chapter introduces the various components of each alternative. The affected environment and likely environmental effects associated with each alternative will be discussed in Chapter 3.

B. Alternatives Considered In Detail

The Forest Service developed three alternatives to cover the broad range of issues involved in rerouting the CDT. The alternatives include: 1) Alternative A – No Action, 2) Alternative B – Use of the Existing Colorado Trail, and 3) Alternative C – The Realignment of the CDT. Maps of the alternatives are available in Appendix B. Large-scale maps are available through the Gunnison, Leadville, and Salida Ranger District offices. Table 2-1 provides a comparison of the alternatives by trail distance and type after project implementation. Alternatives B and C have two trail options at Twin Lakes. The mileages for each option are shown (e.g., X/Y) in the following tables. The first number represents the mileage utilizing the Lake Creek bridge option; the second number represents the mileage utilizing the Twin Lakes bridge option. These options are further discussed in the alternative descriptions below. In order to simplify the comparison of impacts for each alternative, only the Lake Creek bridge option mileages will be shown for the remainder of the document, unless otherwise noted.

Table 2-1. Trail Type and Distance (Miles) by Alternative after Project Implementation. Alternative A* Alternative B Alternative C Motorized Trail 19.4 0.0 0.0 Non-Motorized Trail 42.3 76.8 / 71.9 90.1 / 84.3 Existing Motorized Roads 19.4 12.1 0.0 Total 81.1 88.9 / 84.0 90.1 / 84.3 Source: USFS Geographic Information System (GIS) *Note: Alternatives A and C end at Monarch Pass, whereas Alternative B ends at South Fooses Pass.

Each alternative will be comprised of a combination of existing, reconstructed and newly constructed trail. Table 2-2 describes each alternative by trail construction type. Existing, reconstruction, and new construction are defined as follows:

• Existing – Trail segments that are part of the present Forest Service trail system and primarily meet trail standards and specifications for pack and saddle stock use.

• Reconstruction – Existing system trail segments will be reconstructed 1) to meet Forest Service pack and saddle stock trail standards as defined in Forest Service Handbook (FSH) 2309.18 Trails Management Handbook (U.S. Forest Service 1991b), 2) to avoid known resource issues (e.g., erosion), and 3) to avoid excessively steep sideslopes. Reconstruction may include resurfacing the trail tread, relocating trail segments to an

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adjacent area on appropriate grades or away from sensitive resources, and the installation of stabilization and drainage structures (e.g., water bars, rock steps, and turnpikes). Reconstruction also includes the restoration of associated abandoned trail segments.

• New construction – New trail segments will be constructed according to pack and saddle stock trail standards on locations where trails do not presently exist. New construction segments will provide non-motorized routes parallel to motorized trails and roads that will remain open to motorized use.

Table 2-2. Existing, Reconstruction and New Construction Mileages. Alternative A Alternative B Alternative C Existing 81.1 81.3 / 77.2 32.0 / 28.1 Reconstruction 0.0 3.2 / 2.0 15.8 / 14.1 New Construction 0.0 4.4 / 4.8 42.3 / 42.1 Totals 81.1 88.9 / 84.0 90.1 / 84.3 New trail system miles* 0.0 4.4 / 4.8 31.7 / 31.5 Source: USFS GIS *New trail system miles are equal to the difference between the new construction mileage and the trail closure mileage. Trail closures are discussed in the individual Alternative descriptions.

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1. Actions Common to All Alternatives

All alternatives use segments of the existing CDT and Colorado Trail from Halfmoon Creek to Twin Lakes. As illustrated on Map 2-1 (A-C), all alternatives converge at Twin Lakes Reservoir. Twin Lakes are glacially formed lakes, which have been enlarged to provide additional storage for the Fryingpan-Arkansas Water Storage Project. The Bureau of Reclamation A. Alternative A – Existing CDT on Existing Road, Bridge, (BOR) is responsible for construction, and Trail. operation, and maintenance of water reclamation works, which include dams, spillways, a power plant, raceway, forebay reservoir, switchyard, maintenance buildings, appurtenant works, roads, administrative sites and other associated facilities. The Forest Service administers all other lands, including the Interlaken Historic District, based on a Memorandum of Agreement (USDI Bureau of Reclamation 1984).

All routes have the option of following an easterly alignment around Twin Lakes. B. Alternative B – CDT on Colorado Trail to New Bridge at Lake Creek or to New Bridge Option Between Twin However, the use of the dam is prohibited Lakes. in all alternatives due to existing BOR dam safety encroachment regulations relating to Homeland Security (USDI Bureau of Reclamation 2005).

No additional outfitter and guide service days would be allocated, nor would any existing service days be reallocated under any alternative presented in this EA. Service day allocations are not analyzed in this decision process. Additional outfitter and guide service days may be allocated or reallocated on CDT segments following the completion of a separate capacity C. Alternative C – CDT Reroute to New Bridge at Lake study, needs analysis, and environmental Creek or to New Bridge Option Between Twin Lakes. analysis, or based on availability in current Map 2-1. A, B, C – Twin Lake Options. capacity analyses.

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2. Alternative A - No Action – Existing CDT

The No Action Alternative includes a total of 81 miles of trail; of this, 39 miles are motorized or on existing road and 42 miles are non-motorized (Table 2-1). This alternative does not include any new construction or reconstruction of trail (Table 2-2). This alternative is located in the general proximity of the Continental Divide (Map B-1 and Map B-2).

This alternative would remain on the existing motorized and non-motorized CDT alignment. Motorized roads and trails comprise approximately 48% of the existing CDT. Current trail management direction would continue to guide management of the CDT in the Study Area. The existing CDT between Halfmoon Creek and Monarch Pass would continue to be maintained as funding permits.

As described in Actions Common to All Alternatives, use of the existing trail Figure 2-1. Current Trail Alignment on State Highway across the dam is no longer permitted. 82 Bridge Showing Limited Shoulder for Trail Users. With this alternative, trail users would continue to use the bridge on Colorado State Highway 82. No Colorado Department of Transportation (CDOT) regulations currently prohibit the use of the bridge by trail users (CDOT 2005). Safety concerns, especially for pack and saddle stock trail users, are present due to the lack of a suitable shoulder on the bridge (Figure 2-1).

Annual monitoring would occur in this alternative to evaluate safety concerns, interactions between motorized and non-motorized recreation users, and overall satisfaction levels related to the nature and purpose of the CDT. Additional measures to rectify site-specific problems, based on monitoring results, may be implemented as part of separate planning processes and after additional environmental analyses.

Currently, mountain biking is allowed on all segments of trail, except on those segments that are located in Collegiate Peaks Wilderness (mechanized travel is prohibited within all Forest Service designated wilderness). Approximately 75 miles of the existing CDT is available for mountain bike use with the No Action Alternative. However, of the total miles available to mountain bike use (75 miles), only 35 miles are on non-motorized singletrack. This alternative would not change the amount of trail available to mountain bike use. Presently, 78 miles of trail are designed for or are passable to pack and saddle stock users. Approximately 3 miles of trail are not presently designed for pack and saddle stock use; this is primarily in the Lake Ann Pass area.

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3. Alternative B – Colorado Trail Corridor

Alternative B would utilize the majority of the existing 90-mile segment of the Colorado Trail between Halfmoon Creek and South Fooses Pass as the CDT corridor (Map B-3 and Map B-4). The actual mileage for analysis of this segment is 88.9 miles, or 84.0 miles depending on the Twin Lakes area bridge option selected (discussed below). Because 12.1 of the 88.9 miles are presently routed on existing roads open to motorized traffic, only the 76.8 non-motorized miles of this Colorado Trail segment would be officially “located” as the CDT (Table 2-1). The remaining miles of the Colorado Trail would be utilized as connections to the officially “located” segments of the CDT on an “interim” basis (as outlined in the 1985 Comprehensive Plan) to provide a continuous travel route until relocations to routes that more closely meet the nature and purpose of the CDT can be completed. “Interim” utilization of these existing Colorado Trail connectors is necessary due to timing and cost issues related to the adjacency of private land and private land access.

Between Halfmoon Creek and Twin Lakes, this alternative utilizes the current general location of the existing CDT, but incorporates five realignments to address motorized use and resource and safety issues (Table 2-3). A viable and economically feasible public land corridor was available along this reach of trail to include these construction and reconstruction projects in this analysis effort. This alternative includes the construction of an access spur trail from the South Elbert trailhead (adjacent to County Road 24) to the proposed realignment near the west end of Lakeview campground. These five realignments would result in the new construction or reconstruction of 7.6 miles of trail with the Lake Creek bridge option, or 6.8 miles of trail with the Twin Lakes bridge option (Table 2-2).

Alternative B would also utilize the existing Colorado Trail south of Twin Lakes to South Fooses Pass by officially “locating” the CDT onto non-motorized segments of the Colorado Trail. Motorized segments of the existing Colorado Trail would be used as connectors between the non-motorized segments. This route traverses the eastern, forested shoulder of the Sawatch Range to the headwaters of South Fooses Creek, 4.5 miles south of Monarch Pass. The alternative is primarily below tree line and in some locations is located up to 10 miles from the Continental Divide.

Table 2-3. Alternative B Realignment Segments. Map Symbol Segment Name Miles Action Needed 1 North Elbert 0.69 Reconstruction 2 Herrington Creek 0.17 Reconstruction 3 Herrington Ridge 0.55 Reconstruction 4 South Elbert 2.52 New Construction 5 South Elbert Trailhead 0.18 New Construction 6 Twin Lakes Bridge Option 1.55 New Construction 7 Interlaken (Twin Lakes Bridge option only) 0.53 New Construction 8 Interlaken (Lake Creek Bridge option only) 1.18 Reconstruction 9 Lake Creek Bridge Option 1.72 New Construction 10 South Twin Lakes 0.69 Reconstruction

Approximately 1.4 miles of abandoned trail between Halfmoon Creek and Twin Lakes will be stabilized and naturalized as a result of relocating trail segments during reconstruction efforts.

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Trail stabilization would include constructing check dams and disguising the abandoned trail from trail users. Naturalization includes filling gullied sections with rock and organic soil, transplanting native vegetation, and seeding with native seeds gathered locally.

At Twin Lakes, this alternative includes two options for avoiding Homeland Security issues at the BOR dam and safety concerns at the State Highway 82 bridge crossing: 1) a foot and stock bridge across Lake Creek between the dam and State Highway 82 and, 2) a foot and stock bridge at Twin Lakes bridge between the two lakes at Deception Point. Example bridge photos and drawings are included at the end of this section (Figures 2-8, 2-9, 2-10, and 2-11). Additional information on the two options – the Lake Creek bridge or the Twin Lakes bridge – can be found in Appendix C, Bridge Elements and Standards.

The Lake Creek bridge option includes approximately 0.5 mile of new trail construction in order to connect the CDT to a new 100-foot fixed stringer bridge on the easterly side of Twin Lakes, across Lake Creek (see Map 2-1B). As described in Actions Common to All Alternatives, the rerouted trail would comply with BOR dam safety buffer distances and would avoid the use of the existing State Highway 82 bridge crossing. In addition, the trail from the Interlaken Trailhead to the Interlaken Historic Site would be reconstructed according to American Disabilities Act (ADA) standards.

The Twin Lakes bridge option includes a direct crossing of Twin Lakes on a new non-motorized 300-foot fixed stringer bridge between the two lakes, also shown in Map 2-1B. This option would require the construction of approximately 1.5 miles of new trail to connect the existing CDT to the proposed bridge. This option provides a direct route for trail users using the CDT, access to camping and access to the Interlaken Historic District. The Twin Lakes bridge and the trail to the Interlaken Historic Site would be constructed according to ADA standards.

Either bridge option would be constructed according to ADA standards. Bridge dimensions include a 4-foot width, 3-4 foot high guardrails along both sides, and would require placing of large abutments. Both structures would require engineering design and certification prior to construction.

This alternative includes the construction of two additional bridges north of Twin Lakes at Bartlett Gulch. These bridges would be less than 20 feet in length and would be constructed to pre-approved and pre-designed Forest Service standards and specifications. A summary of the additional types of stream crossings for this project follows:

• Up to 2 puncheon style bridges, 8-18 feet in length, would utilize either wood or steel truss stringers, include 3-foot high guardrails, and natural appearing wood decking 40-48 inches wide. Abutments would utilize any natural features or be constructed from treated timbers.

Annual monitoring would be completed as part of this alternative to evaluate interactions between motorized and non-motorized recreational users and overall satisfaction levels related to the nature and purpose of the CDT. If monitoring reveals the evidence of conflicts between user groups, or unacceptable “satisfaction” levels with regard to the nature and purpose of the CDT on specific segments of this alternative, future reroutes may be needed. If reroutes are deemed to

2-6 Chapter 2 Environmental Assessment Continental Divide National Scenic Trail Relocation be the appropriate response to these issues, subsequent National Environmental Policy Act (NEPA) analyses will be required.

Currently, mountain biking is allowed on all segments of the existing Colorado Trail, except on those segments that are located in Collegiate Peaks Wilderness (Map B-7 and Map B-8). As present levels of mountain bike use on the Colorado Trail do not substantially interfere with hiking and pack and saddle stock use, approximately 72 miles of the Alternative B alignment would be available for mountain bike opportunities, including 60 miles of singletrack. This alternative adds approximately 2.6 miles of singletrack to the total mileage available for mountain bike use within the Study Area. The additional mileage is a result of trail relocation from motorized to newly constructed non-motorized trail segments. The implementation of Alternative B would not result in the closure of any existing routes to mountain bike use. Presently, the entire length of this alternative is designed for or is passable to pack and saddle stock users.

Trail segments that comprise the existing CDT would remain open as local trails and would follow current trail management direction for allowed and managed uses.

4. Alternative C – Proposed Action – CDT Realignment

Alternative C includes total mileages of 90.1 miles or 84.3 miles, depending on the Twin Lakes area option selected, as described below. This alignment would be entirely non-motorized (Table 2-1). This alternative would require the new construction or reconstruction of 58.1 miles for the Lake Creek bridge option or 56.2 miles of trail for the Twin Lakes bridge option (Table 2-2).

This alternative utilizes the current general location of the existing CDT, but incorporates reroutes in order to better fulfill the intent of the CDT (Map B-5 and Map B-6). The reroutes also create a completely non-motorized route between North Halfmoon Creek and Monarch Pass. As illustrated in Maps B-5 and B-6, key rerouted segments of the trail are located in areas between Halfmoon Creek and Twin Lakes, Clear Creek to Texas Creek, Texas Creek to Wildcat Gulch, Chalk Creek to Hancock Lake, and Mount Aetna to Hunt Lake. Specific realignment locations are labeled on Maps B-5 and B-6 and are detailed in Table 2-4. This alternative includes approximately 90 miles of non-motorized trail. The existing motorized trails and roads (approximately 39 miles) presently designated as the CDT would remain open as local travel routes and would follow current trail management direction for allowed and managed uses.

Table 2-4. Alternative C Realignment Segments. Map Symbol Segment Name Miles Action Needed 1 North Elbert 0.69 Reconstruction 2 Herrington Creek 0.17 Reconstruction 3 Herrington Ridge 0.55 Reconstruction 4 South Elbert 2.52 New Construction 5 South Elbert trailhead access 0.18 New Construction 6 Twin Lakes bridge option 1.55 New Construction 7 Lake Creek bridge option 1.78 Reconstruction 7 Lake Creek bridge option 1.7 New Construction

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Map Symbol Segment Name Miles Action Needed 8 Interlaken (both bridge options) 1.25 Reconstruction 9 Rockdale 1.97 New Construction 10 Winfield access 0.36 New Construction 11 Winfield 0.98 New Construction 12 South Fork Clear Creek 1.88 New Construction 13 Old Silver Creek 0.51 Reconstruction 14 Hamilton 3.35 New Construction 15 Lake Ann Pass 1.83 Reconstruction 16 Prospector 6.17 New Construction 17 Waterloo 0.3 Reconstruction 18 Texas Creek 0.17 Reconstruction 19 South Texas 4.12 Reconstruction 20 Cottonwood View Peak 1 spur 0.06 New Construction 21 Cottonwood View Peak 2 spur 0.67 New Construction 22 CotTin 17.64 New Construction 23 Tunnel Gulch 1.95 Reconstruction 24 Hancock 2.77 New Construction 25 Middle Fork 2.04 New Construction 26 Boss Lake 1.11 Reconstruction 27 Hunt Lake 1.38 Reconstruction

This alternative includes the construction of several trail spurs to provide access from trailheads or to viewpoints:

• The South Elbert trailhead spur (adjacent to County Road 24) would connect to the proposed realignment near the west end of Lakeview campground. • The Winfield spur, located east of the historic site of Winfield, would allow through- hikers loop access to experience the historic site’s interpretive opportunities. • Two spur trails would be constructed at Cottonwood Pass to provide access to scenic viewpoints.

This alternative would include the construction of up to 11 bridges between 6 feet and 300 feet in length and up to four armored stream fords, to protect fragile stream crossings or facilitate access across bodies of water that would normally be difficult to traverse especially during high water periods. At Twin Lakes, this alternative includes two options for avoiding Homeland Security issues at the BOR dam and safety concerns at the State Highway 82 bridge crossing: 1) a foot and stock bridge across Lake Creek between the dam and State Highway 82, and, 2) a foot and stock bridge at Twin Lakes bridge between the two lakes at Deception Point. Example bridge photos and drawings are included at the end of this description (Figures 2-8, 2-9, 2-10, and 2-11). Additional information on the two options – the Lake Creek bridge or the Twin Lakes bridge – can be found in Appendix C, Bridge Elements and Standards.

The Lake Creek bridge option includes approximately 0.5 mile of new trail construction in order to connect the CDT to a new 100-foot fixed stringer bridge on the easterly side of Twin Lakes, across Lake Creek (see Map 2-1C). As described in Actions Common to All Alternatives, the rerouted trail would comply with BOR dam safety buffer distances and would avoid the use of the existing State Highway 82 bridge crossing. In addition, the trail from the Interlaken Trailhead to the Interlaken Historic Site would be reconstructed according to ADA standards.

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The Twin Lakes bridge option includes a direct crossing of Twin Lakes on a new non-motorized 300-foot fixed stringer bridge between the two lakes, also shown in Map 2-1C. This option would require the construction of approximately 1.5 miles of new trail to connect the existing CDT to the proposed bridge. This option provides a direct route for trail users using the CDT, access to camping and access to the Interlaken Historic District. This direct route would save the user approximately five miles of travel around the reservoir outlet. The Twin Lakes bridge and the trail to the Interlaken Historic Site would be constructed according to ADA standards.

Either bridge option would be constructed according to ADA standards. Bridge dimensions include a 4 foot width, 3-4 foot high guardrails along both sides, and would require placing of large abutments. Both of these structures would require engineering design and certification prior to construction.

The remaining bridges and fords would be less than 20 feet in length and would be constructed to pre-approved and pre-designed Forest Service standards and specifications. Stream crossings in the Collegiate Peaks Wilderness would include primitive armored fords, except for the crossing of Silver Creek in the South Fork of Clear Creek drainage. This stream would be crossed with an all-natural puncheon style bridge 16 feet in length. A summary of the additional types of stream crossings for this alternative follows:

• Up to 7 puncheon style bridges between 11 and 20 feet in length. These bridges would utilize either wood or steel truss stringers. They would have 3-foot high guardrails. Decking between 40 and 48 inches in width would be natural appearing wood with running surfaces of structural lumber. Abutments would utilize any natural features or be constructed from treated timbers. • Up to 3 puncheon style bridges between 5 and 10 feet in length. These bridges would utilize wood stringers. They would not include guard rails but would have 4-6-inch high side rails. Decking between 36 and 48 inches in width would be natural appearing wood. Abutments would utilize natural features or rock drywall. • Up to 4 armored stream fords between 6 and 16 feet in length. All fords will include a cleared midstream pathway between 36 and 48 inches in width for stock passage, upstream stepping rocks placed above the high water level, downstream spillways constructed of either rock or logs, and armored entry and exit ramps (length depends on depth of stream crossing).

This alternative proposes the consolidation of the Mt. Huron and existing Silver Creek trailheads in the Upper South Fork of Clear Creek basin. The consolidation is necessary to minimize impacts to fragile riparian resources in the South Fork of the Clear Creek drainage. This trailhead would provide access for the Mt. Huron trail (#1462.22) and the realigned CDT in the South Fork of Clear Creek drainage. This alternative also proposes closing and naturalizing 1.2 miles of the Silver Basin trail (#1462.1) from above the proposed CDT location to the terminus in Silver Basin, the closure of 0.9 mile of the Huron Basin trail (#1462.3) from the Hamilton town site to the terminus at the old mine, the closure of 3.0 miles of the Lake Ann trail from the Mt. Huron trailhead to a point a quarter-mile northwest of Lake Ann, and the closure of approximately 4.0 miles of the Pear Lake-Clohesy Lake trail (#1461) from south of Clohesy Lake to Pear Lake. Overall, closing these routes would minimize impacts to fragile sub-alpine

Chapter 2 2-9 Continental Divide National Scenic Trail Relocation Environmental Assessment resources in the Collegiate Peaks Wilderness. The Huron Basin and Silver Basin trails presently receive little use and are located on abandoned roads that are difficult to maintain as a trail. The Lake Ann trail is proposed for closure and realignment to address the presently inappropriate alignment in riparian areas and on unstable slopes. A primary reason for the Pear Lake-Clohesy Lake closure is to protect the wilderness character of this area, which is proposed for pristine management area prescription. Furthermore, the closure of this trail would minimize the potential for user-created impacts in North Texas Creek.

This alternative also includes changing the management objective for The Apostles Basin trail (#1462.2) from a “Most Difficult” hiking trail to a way trail. The reason for this management objective change is to convert the trail to a different trail standard in order to provide a range of travel route opportunities, including minimally developed routes, in the Collegiate Peaks Wilderness.

Relocating trail segments during reconstruction efforts would result in approximately 4.5 miles of abandoned trails. These trails would be stabilized and naturalized. Trail stabilization would include constructing check dams and disguising the trail from trail users. Naturalization includes filling gullied sections with rock and organic soil, transplanting native vegetation, and seeding with native seeds gathered locally.

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Trails would be constructed or reconstructed according to the “More Difficult” pack and saddle stock trail standards, as found in the Trails Management Handbook (U.S. Forest Service 1991b) and in Table 2-5 (also see Figures 2-2, 2-3, 2-4, and 2-5 for examples). Trails would be designed for hiking and pack and saddle stock use during the snow-free season. The location and layout of the realignments would not be designed for winter use. This trail standard would provide a primitive and challenging trail experience. The trail Figure 2-2. Example of Armored Trail in Riparian layout and design process has ensured that Environment, including Open Drain and Turnpike. no segment exceeds a 25% grade as directed by the Trails Management Handbook. The majority of the trail averages a maximum of 12-15% grade in order to minimize impacts from pack and saddle stock use on the trail tread and to minimize maintenance needs and associated costs. The trail would not be designed or managed for mountain biking.

With Alternative C, approximately 46 miles of trail would be available to mountain bike use (Maps B-7 and B-8). However, trails within the Collegiate Peaks Wilderness, between Cottonwood Pass and the Tincup Pass road, and between Sheep Gulch and the Silver Basin Figure 2-3. Example of Trail in Sub-alpine Environment. trail within the Clear Creek drainage would be closed to mountain bike use. Those sections outside of designated wilderness would be closed to mountain bike use to protect resources, particularly fragile alpine soils and plants, steep sideslopes and highly erodible soils, and in locations where they are in conflict with the nature and purpose of the CDT. All 46 miles available to mountain bikes would be located on singletrack. This alternative would add 7.5 miles to the total mileage available to mountain bike use in the Study Area. The additional mileage would be the result of trail relocation from motorized routes to non-motorized routes Figure 2-4. Typical Trail Below Treeline with Non- wilderness Trailhead Identification Signing.

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Table 2-5. Trails Management Handbook “More Difficult” Standard. Criteria Pack and Saddle Trail Grade: Maximum Sustained Pitch 15% Length 300’ Maximum Pitch 25% Turning Radius >3 feet Length of Day Trip (round trip) <10 miles Length of One-half Day Trip (round trip) <5 miles Clearing: Width 6’. Pack clearance must be 3’ from a point 30” above a grade of tread. Height 8’ Tread: Width 24” maximum for typical trail; Up to 36” for structures and steep sidehills, Surface Leave roots and imbedded rocks. Cross-drains permanent with natural roots, rock or imbedded logs. Source: FSH 2309.18, Trails Management Handbook (U.S. Forest Service 1991b)

Traditional trail construction techniques (e.g., cross-cut saws, hand-drilling, and other non- motorized and non-mechanized techniques) would be used in the Collegiate Peaks Wilderness. Prior to construction in the Collegiate Peak Wilderness, identified noxious weed populations would be treated. The minimum tool to treat noxious weeds in the wilderness would be utilized.

Fifteen to 20 new campsites would be established along new trail alignments with this alternative; however trail users would not be required to camp in established camping areas. Campsites would be primarily located outside of wilderness. Those located within Figure 2-5. Typical Trail Cross-Section. wilderness would be minimally established. Approximately 3-6 sites would be designed to accommodate groups larger than six people, 3-6 sites would be designed to accommodate pack and saddle stock users, and the remaining sites would be designed to accommodate small groups of less than six people. Typical features of all established campsites would include natural-appearing flattened tent pad areas and one natural rock fire ring per site (Figures 6 and 7). No pit toilets would be installed; trail users would instead be encouraged to dispose of human waste using the cathole method. All sites would be located a minimum of 100 feet away from the trail, water sources, and other campsites. The sites designed for pack and saddle stock use would be located in areas with adequate feed

2-12 Chapter 2 Environmental Assessment Continental Divide National Scenic Trail Relocation and access to water for pack and saddle stock animals; would accommodate larger groups; and, if located outside of wilderness, would potentially have facilities to assist in containing animals such as hitching rails. Campsites located outside of wilderness may be signed. These sites have been located in areas that minimize impacts to soils, vegetation, and water resources. Campsites would be located at or below tree line to provide shelter from inclement weather.

Figure 2-7. Typical Campsite with Natural Rock Fire Ring and Natural Log Benches.

Figure 2-6. Typical Natural Rock Fire Ring at Campsite.

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Figure 2-8. Typical Log Ford Drawing and Figure 2-9. Typical Rock Ford Drawing and Cross-Section. Cross-Section.

Figure 2-10. Typical Medium Size Non- Figure 2-11. Photo-simulation of Potential Twin Lakes Bridge Option. wilderness Bridge.

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C. Alternatives Considered but Eliminated from Detailed Study

The Forest Service considered but eliminated a number of alternatives because they did not meet the nature and intent of the CDT, were not feasible due to construction limitations, or would have resulted in unacceptable resource impacts. Alternatives considered but dismissed are described below.

1. Convert Motorized Routes to Non-Motorized Routes

This alternative would focus on closing routes that are presently designated as CDT and are open to motorized uses. Those routes that have legal mandates to remain motorized routes (such as county roads) would not be addressed by this alternative. Reroutes would be constructed around those sections that would remain open to motorized uses.

This alternative was dismissed because closures of existing roads and motorized trails, as identified during public scoping meetings, would unacceptably impact established travel access and other recreation user groups. These closures would also conflict with existing Forest Plan Management Area guidance for MAs 2A and 2B (see Tables 1-1 and 1-2 for descriptions of these MAs).

2. Locate New Trail in Other Locations

A thorough analysis of all potential trail locations was conducted by the Forest Service. A number of trail alignments were evaluated and dismissed due to construction feasibility, resource impacts, or incompatibility with the intent and purpose of the CDT. Alignments were evaluated by Forest Service staff using resource information and site reconnaissance. Details on all alignments are contained in the Project Record. Major alignments that were dismissed included:

• Turquoise Lake to South Fork Clear Creek via Independence Pass. • Missouri Gulch / Pine Creek / Frenchman’s / North Cottonwood Creek. • Browns Pass / Denny Creek / Gladstone Ridge / Poplar Gulch / Woodchopper Creek. • Traverse Mt. Elbert and west of Mt. Elbert to Clear Creek. • Lake Fork of Clear Creek / Clohesy Lake / Pear Lake / North Texas Creek. • Parallel trail to Timberline Trail outside of the Collegiate Peaks Wilderness.

Key considerations for dismissal include the following:

• Trail alignments that would cause excessive impacts to wetlands and riparian areas, including the need to construct extensive boardwalks. Trail alignments that would have impacted areas with existing resource problems, such as erosion, stream sedimentation, and trail rutting. • New trail segments that would need excessive grade trails and/or numerous switchbacks, and would result in several large elevation gains and losses.

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• New trail segments that would be located too far from the Continental Divide to maintain the character of the CDT. • Trail alignments that would lack sufficient access to other system trails or trailheads. • Trail alignments that directly cross or are unacceptably close to private land. • Trail alignments that would require the construction of bridges in unstable locations. • Construction of certain trail alignments that would negatively affect areas that have potential for pristine management area prescription designation, or would negatively affect wilderness character. • Trail alignments that utilize very popular trails to 14,000-foot peaks. Cumulative impacts from additional trail and camping use would exceed Forest Plan standards. • Trail alignments that are excessively long and circuitous. • Trail alignments that utilize areas containing unstable soil resources; new trail construction or increased use of these areas may cause additional detrimental effects. • Trail alignments that would contain continuous visual impacts. • Trail alignments that would require excessive construction costs and numerous trail structures. • Trail alignments that would negatively impact wildlife, especially relating to cover availability. • Trail alignments that would incorporate a non-motorized trail in an area specified for motorized recreation. • Trail alignment that would be located in close proximity to conflicting Forest Management activities (i.e., timber sales).

3. West Twin Lakes Route

The 1993 FEIS Record of Decision (ROD) directed that the CDT follow a westerly alignment around Twin Lakes (U.S. Forest Service 1993a). The trail was initially located consistent with this direction, including a bridge crossing of Lake Creek west of Twin Lakes. The bridge washed out within the first season of use. After this event, the trail was rerouted to the eastern end of Twin Lakes to utilize an existing stable crossing on the BOR dam. A western route around Twin Lakes, including utilizing the existing Willis Gulch bridge, was reconsidered as part of this analysis. However, due to riparian and wildlife issues, site feasibility concerns for sustainable crossing of a continuously shifting stream channel, private property issues, and a permanent seasonal area closure to protect “a threatened, endangered, rare, unique, or vanishing species of bird” (36 CFR 261.53(a)), this alignment was dismissed from further consideration.

D. Comparison of Alternatives Effects

Table 2-6 provides a general summary comparison of effects by alternative. Additional information regarding the effects of each alternative can found in Chapter 3.

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Table 2-6. Comparison of Alternative Effects. Resource Alternative A Alternative B Alternative C Hydrology and No new soil disturbance or Approximately 1.6 acres of soil Approximately 11.8 acres of Soils stream crossings are disturbance is planned and three new soil disturbance would planned. This would result new stream crossings. This occur. Fourteen larger stream in minor impacts to soils would result in minor impacts to crossings are planned. The and hydrology due to soils and hydrology due to miles of trail located in the increased use of trail increased use of trail located WIZ* is anticipated to be over 5 located near or adjacent to near or adjacent to streams. miles, resulting in only minor streams. new impacts to stream systems. Riparian and No new impacts to Result in a minor impact to Result in a minor impact to Wetlands wetlands or riparian areas. approximately 0.6 acre of approximately 2.0 acres of Indirect impacts to riparian riparian habitat. Indirect riparian habitat. Indirect areas due to the proximity impacts to riparian areas due to impacts to riparian areas due to of trail within the WIZ. the proximity of trail within the the proximity of trail within the WIZ. WIZ. Cultural No new impacts to cultural Impacts to cultural resources if Impacts to cultural resources if Resources resources. mitigation is not implemented. mitigation is not implemented. Opportunities for interpretation Opportunities for interpretation and education. and education. Wildlife No new impacts to wildlife. Individuals may be impacted Increase in amount of trail in (Federally listed, from increased use concentrated MA 4B. Individuals may be Forest Service near important wildlife areas. impacted by increased use. sensitive, and Management Indicator Species) Fisheries and No new trail construction. Approximately 10 miles of trail Approximately, 6 miles of trail Aquatic Approximately 9 miles of within the WIZ. Approximately within the WIZ. Approximately Resources existing trail within the 7 miles of new trail construction 58.1 miles of new trail WIZ. or reconstruction, 0.2 miles construction or reconstruction, would be in the WIZ. One new 2.3 miles is in the WIZ. stream crossing. Fourteen new large stream crossings. Vegetation No direct impacts to Minor direct impacts to Direct impacts to vegetation (Federally listed vegetation. Minor indirect vegetation (2.8 acres) as a result (21.1 acres) as a result of and Forest impacts from increase use of construction. Individuals construction. Individuals may Service sensitive and dispersion of noxious may be impacted. Minor be impacted. Minor indirect plants) weeds. indirect impacts from increase impacts from increase use and use and dispersion of noxious dispersion of noxious weeds to weeds. new areas. Recreation, Decrease in user Decrease in user satisfaction. Increase in user satisfaction. satisfaction. User conflicts Overcrowding on Colorado Meets the intent of the CDT continue. Only partially Trail. User conflicts continue. trail. Reduces user conflicts meets the intent of the Does not fully meet the intent of Improves recreation CDT. Decreases pedestrian the CDT. opportunities. safety. Wilderness Provides unofficial access Concentration of users in one Increase in amount of into the primitive and location (eastern portion of wilderness accessible by users. pristine basins. The impacts wilderness), long-term could Potential direct effects include of this unofficial use are affect ability to meet wilderness wilderness fragmentation, resulting in the criteria. Removes CDT user decrease in opportunities for development of user base from western side of solitude, campsite development, created routes. wilderness, may result in local visual impacts, and obvious resource condition evidence of human influence. improvement.

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Resource Alternative A Alternative B Alternative C Socioeconomics Least costly to implement Approximately $658,000 - $1.5 Most costly to implement $2 ($0-$330,000). No million (with Twin Lakes bridge million - $2.8 million (with additional economic benefit option) to implement. Minor Twin Lakes bridge option). to surrounding additional economic benefit to Local and regional economic communities. immediate surrounding benefits. communities. *The Water Influence Zone (WIZ) is defined as the area 100 feet to either side of a stream channel bank, see the Hydrology and Soils and Wetlands and Riparian Affected Environment for more discussion.

E. Design Criteria

Design criteria are management practices that can minimize or eliminate adverse effects resulting from project implementation. Design criteria Common to All Alternatives and Common to All Action Alternatives are discussed below. Design criteria specific to one alternative only, are discussed within the respective alternative description.

1. Design Criteria Common to All Alternatives a. Trail Standards

The CDT would cross through a variety of landscapes. Trail segments would receive various intensities and types of use, depending upon their location and scenery. Forest Service construction standards, Standard Specifications for Construction of Trail (U.S. Forest Service 1996), are used as the standard for all trails constructed or maintained in order to minimize or eliminate environmental impacts and trail maintenance.

• The Forest Service will retain authority to regulate any trail use that is inconsistent with the nature and purpose of the CDT and protection of environmental values within the Study Area. • The trail will be signed and marked according to Forest Service standards and as directed by the CDT Comprehensive Plan. This may include the use of plastic CDT trail signs, or the CDT logo burned into posts used as trail markers. The trail will be clearly signed where it enters designated wilderness to prevent motorized and mechanized use in the wilderness. Signage in wilderness areas will be kept to a minimum and will adhere to Forest Service wilderness signage guidelines. • All trail alternatives will be routed to avoid private property. • Erosion control structures, such as waterbars, drain dips, checkdams, culverts, or French drains will be installed, where appropriate, to control water movement and protect alpine plants. • User-created informal roads and trails will be immediately closed and restored. • The public will be educated on how to use the designated trail system and how to protect natural resources.

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• Trails will be constructed, reconstructed or maintained according to the Trails Management Handbook “More Difficult” Standard (Table 2-4), optimized for pack and saddle stock and hiking (U.S. Forest Service 1991b). • All trails will be monitored over time to ensure that use and trail conditions continue to meet Forest Service Standards and Guidelines as outlined in the Forest Plan. All abandoned trail segments that are restored and naturalized will be monitored to assess the long-term success of stabilization efforts. b. Noxious Weeds

• Incorporate weed prevention practices into trail maintenance projects. • Clean all heavy equipment before entering and exiting Forest Service lands to minimize transporting weed seed. Remove all mud, dirt and plant parts. • To the extent possible, perform trail maintenance working from uninfested areas to infested areas. This will help prevent moving weed propagules from infested areas to adjacent uninfested areas. • Reseed after construction, heavy maintenance, and other soil disturbing activities. Only seed collected from plants on site will be used in revegetation efforts. • Minimize sources of weed seed. If straw is used for stabilization and erosion control, it must be certified weed-free or weed-seed free. • Use only clean fill material from a weed-free source rather than borrowing fill from a weed-infested stockpile, road shoulder or ditch line. • Best Management Practices (BMPs) for weed prevention practices will be followed according to Region 2’s Guide to Noxious Weed Prevention Practices (U.S. Forest Service 2001a). c. Plants and Wildlife

• Minimize disturbance in Management Area 4B: Wildlife Habitat for Management Indicator Species. • Undeveloped areas will be kept as primitive as possible to prevent fragmentation of habitat. Manage outfitter and guide operations and dispersed camping. • Protect known active and inactive raptor nest areas. Extent of the protection will be based on proposed management activities; human activities existing before nest establishment; species, topography, vegetative cover, and other factors. A no-disturbance buffer around active nest sites will be required from nest-site election to fledging (generally 3/1 through 8/15). Exceptions may occur when animals are adapted to human activity or nests or nest stands are not active. • Avoid disturbing threatened, endangered, and proposed species (both flora and fauna) during breeding, young rearing, or at other times critical to survival by closing areas to activities. Exceptions may occur when individuals are adapted to human activity or the activities are not considered a threat.

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d. Soil and Water

The Rocky Mountain Region (Region 2) of the Forest Service has developed the Watershed Conservation Practices Handbook, FSH 2509.25 (U.S. Forest Service 1999a), which provides standards, design criteria, monitoring direction and recommendations for remedial actions to protect soil, water and aquatic life. Region 2 has also established Soil Quality Monitoring Standards to be used for all forest and grassland management activities. The policy for these monitoring standards follows:

• Management activities will be conducted to not exceed the Soil Quality Standards. The emphasis is on protecting the soil resource before excessive damage occurs. • Where excessive soil impacts exist from prior activity, the emphasis shall be on preventing any additional detrimental impact and on reclamation, where feasible.

2. Design Criteria Common to All Action Alternatives

The following design criteria are common to all action alternatives, Alternatives B and C.

a. Trail Standards

• Construct routes according to Forest Service trail design standards, Standard Specifications for Construction of Trail (U.S. Forest Service 1996), so that damage from hiker and pack and saddle stock use to soil, water, and other resources is avoided. • Although site-specific standards may vary, the trail will require only the essential width for foot and pack use in keeping with the National Scenic Trail concept. This means a tread width up to 24 inches, and a corridor cleared of major obstacles to a minimum 6-feet wide and 8-feet high. The trail will avoid unnecessary switchbacks, excessive grades, rock cliffs, talus slopes and impacts to resources, such as soil, water, wetlands, wildlife, etc. Where terrain dictates the need to locate the trail within the above types of areas, appropriate Forest Service construction standards and practices for construction trail in these areas will be followed. • Wilderness trail standards state that the trail will emulate game trails to the greatest extent possible. Trails are not designed, constructed or maintained for speed. Clearing is held to the minimum necessary to permit intended use and at the same time protect wilderness values. Where necessary, trail reconstruction will be undertaken to correct impacts to the resource and/or restore the trail to wilderness trail standards. • During trail location, all efforts will be made to avoid wetlands, riparian areas, cliffs, and steep and/or rocky slopes. Where it is not possible to avoid these areas, appropriate trail construction standards will be incorporated into the trail design. Efforts will be made to relocate existing trails off of excessive trail grade and out of riparian or wet areas where resource (erosion, stream sedimentation, rutting of trail) problems are being experienced, unless other routes will create greater environmental impacts.

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• The trail will be located to avoid hazards, such as persistent snow fields, unstable rock or talus slopes, or high-intensity lightning areas where there is no access to cover. • Bridges, signage and other trail structures will be built according to the Built Environment Image Guide, FSH-710 (U.S. Forest Service 2001b), to be aesthetically integrated with their natural, cultural and experiential context. Bridge design will consider the Recreation Opportunity Spectrum (ROS) and MA zones in which they are located. • Appropriate trailbed stabilization will be incorporated into construction standards for each new trail construction or trail reconstruction. These stabilization methods include, but are not limited to: 1) bridges across streams, 2) elevated trail tread if wet areas are crossed, and 3) drainage structures to reduce water on or under trail (drainage structures may include riprap/hand-placed rock, waterbars and associated water diversion structures, logs, and culverts. • In high use areas, established campsites and signage may be used to limit ecological and social disturbance. • As required by federal and state regulations, all construction/reconstruction projects will comply with mandatory federal and state BMPs as discussed in 33 CFR 323.4(a)(b), 40 CFR 230.10(c). • Route construction crews will inform users of potential hazards and construction work in order to minimize delays for users passing through the Study Area. Portable warning signs will be placed above and below active work areas. Information notices about the project will be posted at the main trailheads of the route section under construction. • Temporary trail closures may be necessary when trail construction poses a risk to visitor safety. When explosives are used to construct trail segments, trail sections will be closed until blasting is complete and work crews have confirmed that all explosives have detonated and the area is safe for re-entry. • To minimize disturbance to riparian plants, soil and wildlife work camps for the Study Area will be located at least 300 feet from any waterway. Basecamps will be located where campsites are intended to be established; the base camp should be move once a month. All solid human waste from the crews and associated volunteers will be hauled out to a sanitary dump station. The Forest Service will flag access routes between the camp area and the main trail; work crews will utilize only this flagged route as access to and from the camp location to establish campsite access routes. Access routes to water sources will be flagged where appropriate. New concentrated-use sites shall be located outside the Water Influence Zone (WIZ), if feasible, and outside riparian areas and wetlands. • Alpine turf, cut from newly constructed trailway, will be used in revegetating abandoned or closed routes. Existing topsoil will be used whenever possible in reclamation efforts. • Trails will be designed to enable access to water at regular intervals along the trail. • Areas of steep sideslopes and unstable soil types will be avoided during trail layout. In those instances where these highly unstable areas cannot be avoided, trail structures (such as retaining walls) will be designed and placed as part of the construction/reconstruction activities in order to minimize erosion and slumping.

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• Onsite material will be used for construction. • In “treadless” areas, the route will be delineated by rock cairns to keep hikers within the use corridor.

b. Noxious Weeds

• Avoid working in weed infested areas if possible. Postpone work until weeds have been eliminated from the site. • All known noxious weed sites traversed by new alignments will be treated prior to project implementation to prevent the spread of these populations. • The Regional Forester will authorize any treatment of weeds in the wilderness prior to implementation. The minimum requirement decision guide (RDG) process will be utilized to seek Regional Forester authorization. • Only seed collected from on-site plants will be used in revegetation efforts. c. Plants and Wildlife

• Trail construction or reconstruction will be confined to the corridor surveyed during the analysis. Prior to completing any work outside the surveyed corridor, unsurveyed areas will be flagged and surveyed for threatened, endangered, and sensitive plant and wildlife species, and the U.S. Fish and Wildlife Service (USFWS) will be consulted if listed species are found. • No trees suitable for bald eagle roosting will be removed. • Trail construction within ½ mile of the known goshawk nest location found in 2005 surveys will occur during periods when the nest is not active such as late in the season after August 15. • Monitoring of goshawk nest site located in 2005 surveys should be conducted as early as possible during the construction window, and if nest and nest stand is determined to be inactive early in the season, construction should occur during this period of inactivity. • In areas of known boreal toad and northern leopard frog populations, all wet area trail crossings will utilize small puncheon bridge structures rather than armored drains or fords. The local Forest Service biologist will be consulted during construction to ensure that the placement of these puncheon bridge structures meets the design need to protect the toad in these locations. • Large snags and snags with cavities that provide habitat for purple martin, boreal owl, Townsend’s big-eared bat, marten or flammulated owl will not be removed.

d. Soil and Water

• All soils are prone to erosion once cleared of vegetation and compacted by use. To reduce the impacts of soil erosion and protect the resource, the trail construction techniques found in FSH 2309.18 Trails Management Handbook (U.S. Forest Service 1991b) will be used as appropriate. These include, but are not limited to, sloping of trail tread for drainage, and log retaining walls.

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• Construct bridges or rock fords for larger stream or river crossings to ensure proper drainage and to minimize erosion and sedimentation. For all other stream crossings, appropriate trail structures such as culverts, French drains, or open rock drains will be installed as directed by the Trails Management Handbook (U.S. Forest Service 1991b). • Soil and water resources will be monitored by a qualified hydrologist during and after construction. • Build erosion resistance into project design to reduce costly maintenance and restoration (Clean Water Act Sections 402(p) and 404); mitigate concurrently with construction (disturbance of more than 5 contiguous acres per project requires a state stormwater discharge permit; a 404 permit would be required if more than 0.5 acre of Waters of the U.S. are disturbed). • Where required by state laws, appropriate permits relating to discharge and sedimentation will be obtained prior to construction. • Locations and designs of all stream crossings (bridges, fords, etc.) will be reviewed both in the office and in the field prior to being constructed by the San Isabel zone and/or forest hydrologist. Oversight of all stream crossing installations will be provided by the San Isabel zone and/or forest hydrologist. • Monitoring requirements dictate that erosion monitoring will take place to ensure that less than 15% of soils in the Study Area are severely impacted. • Avoid soil-disturbing actions during periods of heavy rain or wet soils. This includes times where severe puddling or runoff occurs along the trail, or obvious tracks or ruts can be seen following passage. Periods of heavy snowmelt should also be considered. • The action alternatives will be designed to reduce adverse impacts in riparian habitats, including both direct and indirect effects resulting from damage to vegetation, increased erosion, increased sedimentation, and disturbance. • Designate, construct and maintain recreational travelways for proper drainage, and harden their stream crossings as needed to control sediment. Proper spacing will be determined utilizing the Trails Management Handbook and the Watershed Conservation Practices handbook. • Restore soil disturbance caused by human use to soil loss tolerance levels that are commensurate with the natural ecological processes for the treatment areas. • Construction equipment will be decontaminated before entering different sixth-level watersheds. e. Heritage Resources

• In accordance with the National Historic Preservation Act (NHPA) and Forest Service Manual 2360 (FSM), all significant archaeological sites will be protected (U.S. Forest Service 1990a). Any cultural property found eligible to the National Register of Historic Places (NRHP) will be protected through avoidance or trail relocation. Should an unknown cultural resource site be discovered during trail construction or slope

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stabilization, a cultural resource specialist will be notified and appropriate measures implemented to preserve the integrity of the site. • Trail construction or reconstruction will be confined to the corridor surveyed during the analysis. Prior to completing any work outside the surveyed corridor, unsurveyed areas will be surveyed to identify additional historic and prehistoric sites and evaluate them according to the NHPA. • Provide project managers and contract inspectors with maps and Global Positioning System (GPS) readings indicating locations and extent of all significant or potentially significant cultural properties. Provide direction to avoid these locations and their near vicinities. Provide barriers and/or wrapping for vulnerable cultural properties. Inspect these locations during the progress of the proposed activities to assure that significant cultural sites are protected.

f. Wetlands and Riparian Areas

• Stream crossings and other instream structures will be designed to provide for passage of flow and sediment, withstand expected flood flows, and allow free movement of resident aquatic life. • Install stream crossings to sustain bankfull dimensions of width, depth, and slope and keep streambeds and banks resilient. Favor hardened fords and bridges. • When feasible, keep trails out of wetlands. If trails must enter wetlands, use bridges or raised prisms with diffuse drainage to sustain flow patterns. Set crossing bottoms at natural levels of channel beds and wet meadow surfaces. Avoid actions that may dewater or reduce water budget in wetlands. • Avoid any loss of rare wetlands such as fens and springs. • Keep the number of stream crossings and the extent of sediment sources to a feasible minimum. Avoid sediment loads that damage stream health. • Designate, construct, and maintain recreational travelways for proper drainage and harden their stream crossings as needed to control sediment. • Design all trail and other soil disturbances to the minimum standard for their use and to “roll” with the terrain as feasible. • Establish pack and saddle stock sites and sanitary sites outside the WIZ.

F. Amendments to the FEIS

The 1993 FEIS presented the environmental consequences of the Preferred Alternative, a 753-mile portion of the CDT in Wyoming and Colorado (U.S. Forest Service 1993a).

Within this EA’s Study Area, Alternative A is the same as the preferred route defined in the 1993 FEIS, with the exception of the segment of trail that currently traverses the eastern end of Twin Lakes. (The decision in the 1993 FEIS was to traverse the Lake Creek valley, west of Twin Lakes.) This alternative would continue to implement the direction in the FEIS 1993 ROD, with

2-24 Chapter 2 Environmental Assessment Continental Divide National Scenic Trail Relocation the exception of the segment of trail at Twin Lakes. A western alignment was considered but dismissed; see the discussion on Alternatives Considered but Dismissed in Section C of this chapter.

The trail alignment in Alternatives B and C would vary from the preferred alignment identified in the FEIS between Twin Lakes and South Fooses Pass and the Texas Creek area and Tincup Pass, respectively. Alternatives B and C would require an amendment to the 1993 ROD.

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